What License is Needed to Convert Non-Compliant Guns

[TheRaspyRabbit]

Hello,
I am a new type 07 FFL and we would like to warehouse a few non-California compliant guns for sale and export to other states as well as convert some eligible guns to be California compliant (bullet button, etc.). I am having trouble determining what additional licenses/permits we need to do this and even if it is legal?

If it is permissible to receive and then convert a gun for sale in the state how is the gun documented in the Acquisition and Disposition Record?

[kemasa]

Most of the conversions don't change the type of firearm, so there is not typically an A&D issue.

As far as I know, due to discussions with a person at the BATF, there is no additional permits or licenses that you would need since you have an 07 FFL. As long as you follow all of the rules and regulations, it would be legal. The real questions is what you have to do.

The main issue is in regards to whether it is considered manufacturing, with all the requirements that go along with that. In some cases it might not be, depending on what needs to be done. In other cases it could be, especially considering what some of the FAQs show as being "manufacturing".

The person that I know at the BATF said he is trying to get a FAQ done in this area, but who knows if it will ever happen due to all of the political issues in trying to get it published.

[TheRaspyRabbit]

Thanks a bunch for the info and I would be real interested in the related FAQ you mentioned.

To clarify, two example scenarios I am thinking of would be the ability to purchase an off list AR type lower receiver and install a bullet button and either build a gun around this or sell to someone who intends to do the same. The other would be to pick up a complete firearm such as the Hi-Point carbine and then make it Cal compliant by installing a bullet button and 10 round mag. The sticky part here would be the ability to have a non-compliant gun shipped to me....this is what I am thinking requires some other license/permit, Class III maybe?

Thanks again

[kemasa]

http://www.atf.gov/firearms/faq/manufacturers.html

In terms of a non-complaint AR/AK firearm, if it was considered a so-called a-salt weapon, you would need to be an assault weapon permit in order to receive it. If it is just the lower, then it is not semi-auto, nor center-fire, so it would not be considered a so-called a-salt weapon and it could be shipped to CA.

I have heard that the AW permit is expensive and difficult to get.

[Pancho Villa's Armory]

what Kemasa said, I also have the 07 and asked this same question and you would need an AW permit from DOJ to be able to receive non bullet button AR/AK into this state. You can buy the rifle out of state, make Ca legal and then bring it back.

[Eddy's Shooting Sports]

Does the AW permit allow for import? I thought intention was to allow AW dealers to buy RAW's from individual for export from the state.

Do you know of anyone who actually has an AW permit? I thought it was like unicorns.

[Pancho Villa's Armory]

AW permits are expensive and if your not making the big bucks like us table top dealers they are not worth the extra fees. I am close friends with my local chief and getting approval would not be a problem. The problem is the mula!!

[Eddy's Shooting Sports]

do you know how much moola?

[ke6guj]

do you know how much moola?

here's the costs.

FEES:
The BOF's initial dangerous weapons license/permit fee (minus the $32 state and $19 federal fingerprint fees already
paid to obtain electronic fingerprints at an approved Live Scan station), is $321 for the first license or permit, plus $22 for
each additional license or permit.

While dangerous license permit inspection fees pursuant to Penal Code sections 18910, 31110, 32670, and 33320 do not
apply to the initial application, please remain mindful inspection fees are charged with each renewal application at the
following rates: 0 to 4 inventory, $165; 5 to 25 inventory, $750; 26 or more inventory, $1500; out-of-state permit holders
with no California based location, $100.

and "inventory" means each AW that passes through your books during the year. Not how many are actually in your inventory at renewal time.

[TheRaspyRabbit]

Great info....thanks again guys, that gives me the possible options I was looking for. I didn't think that an AR type lower legal unless it had the magazine lock already installed but what you explained sounds right that until you mate it with a semi-auto capable upper and pistol grip it doesn't constitute a prohibited gun...as long as it is an off-list receiver I assume.

[kemasa]

Great info....thanks again guys, that gives me the possible options I was looking for. I didn't think that an AR type lower legal unless it had the magazine lock already installed but what you explained sounds right that until you mate it with a semi-auto capable upper and pistol grip it doesn't constitute a prohibited gun...as long as it is an off-list receiver I assume.

Actually, it also applies to a listed lower. The listed lower is only banned if it is semi-auto. This means that you could make one which is bolt action, single shot, pump action or whatever as long as it is not semi-auto. It does not matter if it is center-fire or not, unlike off-list lowers.

There can still be the issue of being harassed if you have a listed lower that is not a semi-auto since not all LEO might be aware of the actual law.

[Eddy's Shooting Sports]

Actually, it also applies to a listed lower. The listed lower is only banned if it is semi-auto. This means that you could make one which is bolt action, single shot, pump action or whatever as long as it is not semi-auto. It does not matter if it is center-fire or not, unlike off-list lowers.

There can still be the issue of being harassed if you have a listed lower that is not a semi-auto since not all LEO might be aware of the actual law.

So, you're saying a Roberti listed Colt AR15 lower does not need to be registered if it is mated to a bolt action upper?

[ke6guj]

So, you're saying a Roberti listed Colt AR15 lower does not need to be registered if it is mated to a bolt action upper?

IMO, per the exact wording of the law and regs, no, it wouldn't need to be registered.

but unless you personally have the $$$$$ to defend that in court, it is not suggested that you attempt this.

[kemasa]

IMO, per the exact wording of the law and regs, no, it wouldn't need to be registered.

Correct, since it is not a semi-auto firearm.

but unless you personally have the $$$$$ to defend that in court, it is not suggested that you attempt this.

This is also very true as well. It could be profitable in the end since you should win, as well as the ability to sue for wrongfully being arrested, but ...

I received such a lower and called the CA DOJ to ask what to do about it and I was told to just send it back. I learned later that since it was not semi-auto, it was not the issue that I thought that it was.

[personalsecurityzone]

Another option is to have us install the bullet button and ship to you. We have several FFLs in California who buy from us and we then add the bullet button and ship to them. For dealers who buy often we offer a price discount. Our prices are very low anyway though. Most Calif. dealers just tell their customers to order directly from us, and then they make their $ on the transfer fees. However, several buy from us and we add the bullet button. If you have a hicap mag permit we can send the hicap, too, but only if. Just give me a call for info 775-841-1194 or you can also look for what's in stock . . .

Most all rifles that can be made Calif OK are at this link. . .

http://personalsecurityzone.com/cgi-win/order/prodlist.exe/PSZ/?ShortDescription=CALIF&CategoryID=42

Mary Kay at PersonalSecurityZone.com